Open Burning Module 1 | P a g e

Table of Contents

Overview ......................................................................................................................... 2

Objectives ....................................................................................................................... 3

Introduction Lesson Overview ......................................................................................... 4

Introduction Lesson Contents.......................................................................................... 5

Description................................................................................................................... 6

Advantages.................................................................................................................. 7

Disadvantages............................................................................................................. 8

Evaluation Lesson Overview ......................................................................................... 10

Evaluation Lesson Contents.......................................................................................... 11

Regulations................................................................................................................ 12

Waste Stream Evaluation .......................................................................................... 14

Open Burning Site Evaluation.................................................................................... 15

Open Burning Evaluation Questions.......................................................................... 16

Environmental Impact................................................................................................ 17

Environmental Impact Questions............................................................................... 18

Biosecurity................................................................................................................. 19

Public Health Considerations..................................................................................... 20

Public Health Questions ............................................................................................ 21

Planning Lesson Overview............................................................................................ 22

Planning Lesson Contents ............................................................................................ 23

Personnel .................................................................................................................. 24

Waste Classification and Characterization ................................................................ 26

Material, Supplies, and Equipment ............................................................................ 27

Temporary Carcass Storage...................................................................................... 29

Secure Transportation ............................................................................................... 30

Site Suitability ............................................................................................................ 31

Operations Lesson Overview ........................................................................................ 32

Operations Lesson Contents......................................................................................... 33

Incident Management ................................................................................................ 34

Infected Premises Preparation .................................................................................. 35

Open Burning Operations.......................................................................................... 37

Summary....................................................................................................................... 40
Open Burning Module 2 | P a g e

Overview

Welcome to the Open Burning Module of the online Carcass Management Course. 

While completing this module, you may encounter references to the Emergency 

Management Tools; Health, Safety, and Personal Protection Equipment; Secure 

Transport; and to Biosecurity, which are broadly covered in their own separate training 

modules. These modules are found in the Introduction Modules, beginning with the 

Orientation Module. 

Effective management of animal carcasses and associated materials is a critical 

component of a successful response during an animal health emergency. Carcass 

management measures contain, treat, or destroy contaminated or potentially 

contaminated materials in order to:

 Prevent spread of a disease outbreak to protect the nation’s agricultural industry 

 Protect the environment by preventing carcass waste products from 

contaminating soil, water, and air 

 Protect decaying carcasses from insects and scavengers which can transport 

pathogens to other locations 

 Safeguard public health by removing potentially contaminated food products from 

the human food supply 

 Safeguard animal health by removing potentially contaminated feed from the 

animal feed supply

This training module is presented from the perspective that you have already used 

the MLCh Tool (Matrix, Decision Loop, and Checklist) explained in the Emergency 

Management Tools Module and selected open burning as the preferred carcass 

management option.
Open Burning Module 3 | P a g e

Objectives 

This module presents the material in four different lessons: 

 Introduction

 Planning

 Evaluation

 Operations

Upon completing this course, you should be able to:

 Describe open burning as a method for carcass management

 Understand the advantages and disadvantages of open burning 

 Identify personnel health risks associated with open burning 

 Consider environmental risks associated with open burning

 Obtain regulations governing open burning by consulting with state officials

 Identify factors used to evaluate open burning as a carcass management option

 List critical elements when planning open burning

 Recognize key components of open burning operations
Open Burning Module 4 | P a g e

Introduction Lesson Overview

Definition: Open burning involves combustion of waste at high temperatures, converting 

the waste into heat, gaseous emissions, and ash. The gaseous emissions are vented 

directly into the atmosphere without passing through a stack or chimney. Open burning 

is also termed open-air burning, and uncontrolled burning.

The general process of open burning may include: 

 Burning on open land above-ground, in a dug-out pit, or combustible piles (pyres)

 Using combustible materials or fuels such as straw or hay, untreated timbers, 

wood, coal, or petroleum products such as diesel fuel to initiate and/or maintain 

combustion

Figure 1. Burning Carcasses
Open Burning Module 5 | P a g e

Introduction Lesson Contents

This lesson is divided into the following sections:

 Description – Presents the key features of open burning

 Advantages – Describes the benefits of using open burning as a carcass 

management option 

 Disadvantages – Covers the many difficulties and drawbacks associated with 

open burning of animal carcasses
Open Burning Module 6 | P a g e

Description

Open burning is a process which involves constructing a bed of combustible materials 

such as wooden timbers, placing the carcasses on the bed, adding more combustible 

material over the carcasses, and igniting the pile. There is no containment of materials

in this process. Historically, open or uncontrolled burning has been used to thermally 

destroy animal carcasses and associated materials during animal health crises. Open

burning may be termed uncontrolled burning because it has the least opportunity for 

inputs and outputs to be monitored or regulated.

 Neither the fuel nor air inputs can be reliably or accurately controlled, which can 

result in incomplete, smoke-filled and relatively low-temperature combustion

 Carcasses can be burned in open fields, on combustible heaps called pyres, or 

with other burning techniques that are unassisted by incineration equipment

 Many states specifically prohibit open burning of carcasses; state and local 

regulations should always be checked before deciding to use open burning 

 Public perception of open burning can be very negative 

 May result in significant negative traditional and social media coverage

 The potential for aerosol pathogen transmission must be addressed when 

considering open burning 

Figure 2. Fire Trench 
Open Burning Module 7 | P a g e

Advantages 

Open-air burning has a few advantages:

 May be relatively inexpensive

 May eliminate the need for off-site transportation

 Complete incineration combines sterilization and carcass destruction into one 

operation

 Can be used anywhere a permit can be obtained, although it may be difficult to 

meet air emission, solid waste, and fire prevention requirements

 Requires minimal specialized equipment but does need experienced personnel 

Figure 3. Burning Heap (Pyre)
Open Burning Module 8 | P a g e

Disadvantages 

Open burning is an option of last resort, as it has significant regulatory limits, high 

environmental impacts, and very low public acceptance. Other disadvantages include:

 Potentially creating a public nuisance, causing unintended fires, and creating 

permitting challenges

 It is an inefficient and time-consuming process, which

 Requires intensive labor and fuel

 Requires favorable weather conditions

 Requires a suitable species of animal. Carcasses are among the worst 

combustible classification of waste - composed of more than 50 percent 

water. Also, the percentage of animal fat influences the length of time a 

carcass will burn.

 In addition, the bulky nature of some animal species (e.g., cattle) makes it 

difficult to achieve effective mixing of the fuel, air, and carcass material

Figure 4. Cow Rumen
Open Burning Module 9 | P a g e

Disadvantages (cont.)

 Potentially generating excess air pollutants, including smoke and odor 

 Emissions from carcass combustion, like all combustion processes, will 

likely include particulate matter, carbon monoxide, hydrocarbons, heavy 

metals and metal salts, fuel specific chemicals, nitrous particles, sulfur 

dioxide, nitrogen oxides, dioxins and other pollutants

 There is possibility for dispersal of partially combusted particles, laden 

with active pathogens 

 Animals fed arsenic-derived antimicrobials may result in arseniccontaining air emissions as well as arsenic-containing ash

 Fuels that are used may result in toxic air emissions

 Plastic and other materials used to line trucks may create hazardous 

byproducts when burned

 Potentially contaminating the ground water and soil 

 From applying liquid hydrocarbon fuels to the pyre

 From burying ash, produced due to combustion of carcasses. One ton of 

carcasses yields 0.3 tons of ash.

 From burying ash produced due to combustion of wood or other solid nonhydrocarbon fuels

 May require significant and costly ash removal and site remediation 
Open Burning Module 10 | P a g e

Evaluation Lesson Overview

This lesson contains information to help assist you in determining if open burning is a 

suitable method for disposing of carcasses following an animal health incident. 

Factors in the evaluation include: 

 Knowing and understanding applicable regulations

 Identifying the waste stream

 Evaluating the availability and delivery logistics of auxiliary fuel

 Evaluating the open burning site

 Recognizing the environmental impact
Open Burning Module 11 | P a g e

Evaluation Lesson Contents

This lesson presents the following information: 

 Regulations – Covers many of the key regulations governing open burning

 Waste Stream Evaluation – Contains questions to assess the material on the 

infected premises to determine suitable management options

 Incineration Site Evaluation – Has information including questions to assess 

whether or not open burning is suitable for carcass management, including 

evaluating the availability and delivery logistics of auxiliary fuel

 Environmental Impact – Includes a discussion of potential environmental 

impacts, important biosecurity considerations, and public health considerations
Open Burning Module 12 | P a g e

Regulations 

In order to properly manage waste, the waste must be classified so applicable 

regulations can be followed. In general, infected animal carcasses are not classified as 

hazardous under EPA regulations. Depending on the state, infected carcasses may or 

may not be classified as infectious or pathological waste. Because of the complexity of 

environmental regulations, planning and response efforts for waste management should 

include consultation with experienced personnel familiar with all applicable regulations 

in the affected areas. Some laws and regulations which may apply to open burning 

include:

 Clean Air Act for air emissions 

 Resource Conservation and Recovery Act (RCRA) for solid waste management 

 The U.S. Occupational Safety and Health Administration (OSHA) has set 

requirements and recommendations for those engaged in hazardous waste 

operations and emergency response involving disease-causing organisms (29 

CFR 1910)

 State or local Departments of Health may issue regulations that determine which 

wastes are considered ‘regulated’ or require special handling. Check the 

Regulated Medical Waste RMW State Locator to find the classifications. 
Open Burning Module 13 | P a g e

Regulations (cont.)

All waste materials slated for management and/or transport must be correctly classified 

by a certified waste management professional prior to assure that appropriate carcass 

management and transportation methods are selected. The classification of the waste 

will depend upon the specific type of incident and the federal agency with primary 

authority. Refer to the Emergency Management Tools Module for additional guidance. 

Below are some of the considerations for classifying and transporting waste:

 Solid Waste - Most animal related waste generated during a response to an 

animal health incident will be classified as solid waste for carcass management 

purposes

 Medical And Infectious (Solid) Waste - A portion of the waste material associated 

with a response to an animal health emergency may be classified as medical 

and/or infectious waste, such as used sharps or needles, and will be subject to 

state regulations

 Hazardous Materials - If carcasses are moved on public roads, their movement is 

regulated under US Department of Transportation authority, as well as USDA 

authority discussed in the next bullet

 Hazardous material will require packaging, manifesting, and transport to 

an appropriate facility approved to accept the materials in accordance with 

DOT requirements

 It is important to note that the hazardous material classification for 

transportation is not the same as hazardous waste under RCRA

 Permitted Movement – When infected carcasses are permitted to move under 

APHIS/state authority, they will require DOT designation as hazardous material 

 In compliance with 49 CFR 105.5 and 49 CFR 173.134, as well as, other 

related 49 CFR requirements, and

 In compliance with incident-specific state and federal requirements for 

biosecurity, transport method, chain of custody, and cleaning/disinfection 

(e.g., using VS Form 1-27)

 Refer to the NAHEMS Guidelines: Quarantine and Movement Control for 

additional information
Open Burning Module 14 | P a g e

Waste Stream Evaluation 

The following are issues one should consider before starting open burning activities:

 What types of affected material?

 Carcass: type, size, number and condition 

 In-barn manure/litter: type, volume, moisture content, density 

 Stored manure/litter: type, volume, moisture content, density 

 Feed? Quantity and location

 Eggs? Quantity and condition

 Bedding? Non-infected manure compost? 

 Paper products? Other debris? 

 How much material needs to be incinerated? 

 If there is more material than on-site open burning can handle, off-site 

carcass management may be required

 Plastics, treated lumber, and other materials may not be suited for open 

burning because they may produce hazardous air pollutants

 The material from a large outbreak may have to be sent to multiple off-site 

locations if capacities are reached for onsite open burning which may 

increase the risk of biosecurity breaches
Open Burning Module 15 | P a g e

Open Burning Site Evaluation

A number of factors affect the decision to use open burning to manage infected animal

carcasses and related debris. Some factors to consider are listed below:

 Is an agreement or are regulations already in place with the state that allow 

emergency carcass management using open burning? If so, this will help speed 

implementation of the carcass management process.

 How will emissions be monitored to protect public health? Will the pathogen be 

spread by open burning before the material is fully combusted?

 Who owns the land or facility where open burning will occur? Open burning and 

related waste products such as ash and leachate may contaminate the area 

where the burning occurs.

 Is it part of a large poultry or cattle producing company? If so, you may be able to 

access company resources to help with the on-site carcass management

process.

 Can the site be completely secured at all times? What security measures are in 

place? What measures would be needed to make the site secure?

 What actions will be taken to reduce odor and vermin? Ensuring that the 

operation is following regulations and procedures effectively is important to avoid 

any negative publicity surrounding the carcass management activities.

 Can a sufficient supply of appropriate fuel be acquired and delivered?

 Do the applicable permitting authorities allow open burning?

 Can the permit conditions be met? 

 Proximity to water bodies, wells, public areas, roadways, dwellings, residences, 

municipalities, or property lines

 Proximity to historic sites, burial and tribal sites

 Are short (days) and longer term (weeks) climatic and weather factors suitable to 

allow complete incineration and any immediate remediation to be completed?

(e.g., the direction of the prevailing winds) and seasonal conditions (e.g., wet or 

frozen ground)
Open Burning Module 16 | P a g e

Open Burning Evaluation Questions

Crisis management and farm officials should conduct a survey of potential open burning

sites and their overall suitability. Technical expertise will be required for large open 

burning operations at multiple sites during the extended open burning process. 

 Does the open burning plan meet regulatory requirements and does it prevent 

environmental contamination?

 Are on-farm land areas limited? Will this limit the open burning option during 

animal disease outbreaks with resulting high mortalities?

 Will selection of open burning be made jointly by farm owners and the members 

of an incident command structure (ICS) including state or local authorities? 

 Has explicit approval by competent institutions and agencies been received to 

begin open burning?

Many states have orders of priority for carcass management options. The ICS must be 

aware of these and plan to execute carcass management actions, based on these 

priorities.
Open Burning Module 17 | P a g e

Environmental Impact

There are a number of potential environmental impacts from open burning, including 

those listed below:

 Uncontrolled open burning has the potential to generate excess pollutants in the 

form of air emissions, leachate, and residual ash. Open burning may also have

environmental impacts because carcasses have high water content and require 

large amounts of fuel to burn and to sustain the fire.

 Open burning of carcasses, fuel and other material can emit hydrocarbons, 

heavy metals and metal salts, fuel specific chemicals, nitrous particles, sulfur 

dioxide, nitrogen dioxide, dioxins and other pollutants into the air

 Ground water and soil contamination may also result from pollution by 

hydrocarbons

 The volume of ash generated can be significant, requiring onsite burial or 

transportation to landfills

Figure 5. Open Burning Potential Risks (Click on Image to Enlarge It)
Open Burning Module 18 | P a g e

Environmental Impact Questions

 Is there a plan in place to dispose of the ash generated through the incineration 

process? 

 Will ash be considered hazardous waste? 

 What type of confirmatory sampling is required to make the determination 

that the ash is not hazardous?

 Does it have to be buried at a regulated landfill?

 Is the premises in compliance with all permit requirements?

 Does record keeping meet the regulatory requirements? 

 Who will keep the records?

 This is important to identify who may be legally liable, in case there is an 

environmental release in the future 
Open Burning Module 19 | P a g e

Biosecurity 

Biosecurity is a series of management practices designed to prevent the introduction 

and spread of disease agents on an animal production facility. These measures are 

necessary to keep disease agents out of healthy livestock and poultry populations and 

prevent the spread of disease agents from infected groups to uninfected groups within 

the same population.

Below are some biosecurity considerations. For more comprehensive biosecurity 

information, refer to the Biosecurity Module.

 Written plans must be in place to prevent disease spread during transportation, if 

any is required for open burning. For more information see the Secure Transport 

Module.

 Workers who handle infectious carcasses need to take proper precautions and 

should be equipped with appropriate PPE in accordance with site-specific plans. 

Refer to the Health, Safety, & PPE Module.

 In cooperation with appropriate public health agencies, personnel should be 

monitored afterward for signs of illness if pathogen of interest is potentially 

zoonotic

 Proper storage for carcasses awaiting management should prevent scavenging 

by wildlife and access by other vectors

 Some disease scenarios (prions, spore-forming bacteria) are incompatible with 

open burning since temperatures may not be high enough to inactivate the 

disease agent 

NOTE

The agent causing the disease may not be the only agent that poses a risk to 

personnel. Other potential risks may occur from Salmonella, Campylobacter, Q fever 

and coliforms.
Open Burning Module 20 | P a g e

Public Health Considerations

A comprehensive understanding of the type and strain of pathogen as well as other 

pathogens associated with the carcasses is essential to prevent further spread of 

infection and to safeguard human, animal, and environmental safety and security. 

Biosecurity measures along with cleaning and disinfection protocols will be governed by 

the type and strain of pathogen present. The list below outlines some open burning 

considerations:

 Negative public perceptions may be an issue in the event of large-scale (or even 

small scale) on-site open burning. Care must be taken to conduct open air 

burning operations in such a manner that public impact is minimized.

 Off-site open burning or other management options will also require 

transportation of potentially contaminated biomass that may have additional 

public perception implications

 Heightened public health concerns will exist and must be addressed when 

dealing with a zoonotic disease agent 

 Emissions from open burning can include dense smoke containing particulates, 

metals, and other potentially-hazardous by products which can cause short-term 

respiratory problems and possible long-term effects in humans

 Temperatures reached during open burning vary throughout the pyre, so 

pathogens may not be inactivated and could be dispersed with particles

 Disease agents responsible for Transmissible Spongiform 

Encephalopathy (e.g., scrapie, BSE, and CWD) must be subjected to 

temperatures 1,560° F (850°C) for at least 15 minutes, to render them 

noninfectious. It is likely these temperatures will not be achieved in a pyre.

 TSE experts agree that open burning should not be considered a 

legitimate TSE-related carcass management option
Open Burning Module 21 | P a g e

Public Health Questions 

The following questions will help evaluate the public health concerns associated with 

open burning activities:

 Are there incident and site-specific health and safety plans that are approved by 

a credentialed Safety Officer?

 Are open burning operators trained in proper handling of potentially infected

material and the requirements of the health and safety and biosecurity plans? If 

not, will specialized operators be available to oversee the process?

 Is employee health and safety and biosecurity monitored and are the rules

enforced? If the pathogen poses an increased health risk to employees, it is 

important that personnel use required protection and are monitored regularly by 

healthcare workers to ensure they are not exhibiting effects of exposure.
Open Burning Module 22 | P a g e

Planning Lesson Overview

This lesson contains information to help you plan for open burning of carcasses 

resulting from an animal health emergency. Planning is essential to ensure that the 

carcass management tasks are carried out efficiently and unimpeded by a lack of 

resources. Successful management of a large number of contaminated animal 

carcasses requires proper planning to protect workers, the general public, susceptible 

animals, and the environment.

Important considerations include:

 Classifying and characterizing the waste material 

 Identifying suitable open burning sites

 Finding adequate carcass storage facilities

 Assessing availability of secure transportation equipment and materials to safely 

move infected materials to the open burning site
Open Burning Module 23 | P a g e

Planning Lesson Contents

The material in this lesson is divided into the following sections:

 Personnel – Highlights requirements and related issues associated with 

personnel involved with open burning activities 

 Waste Classification – Discusses the procedures necessary to categorize the

various materials being managed so each type can be managed properly

 Materials, Supplies, and Equipment – Provides a list of equipment and supplies 

which might be needed for open burning

 Secure Transportation – Presents important questions to consider before 

transporting carcasses to the open burning location

 Site Suitability – Describes planning considerations for selecting and using an 

open burning site
Open Burning Module 24 | P a g e

Personnel

There are certain planning aspects that are common to all carcass management 

options. Those aspects include human health and safety, biosecurity, and physical 

security, as described below.

 Health and safety – Planning to implement open burning as a carcass 

management option should include measures to protect workers and the public 

from hazards associated with loading infected materials for transport to the burn 

site, and transporting the materials to the open burning site. For more information 

on health and safety practices, refer to the Health, Safety, & PPE Module and the

Secure Transport Module.

 Biosecurity – Planning to use open burning must include strict biosecurity 

measures to minimize disease spread when handling infected materials. For 

more information on Biosecurity practices, refer to the Biosecurity Module.

Warning

Tyvek® and Tychem® fabrics are not flame resistant and should not be used around 

heat, flame, sparks or in potentially flammable or explosive environments. Nomex® fiber 

is suitable for flame hazards, as described on the Dupont® website. 

Disclaimer: This module is not endorsing the product of a specific vendor, but merely 

used the data on this product as an example.
Open Burning Module 25 | P a g e

Personnel (cont.)

 Physical Security – Open burning planning efforts should consider security of 

personnel at the infected premises, security of infected material during transport

to the burn site, and security at the open burning site. Below are some ideas for 

minimizing physical security risks: 

 Provide a single entry point to the infected premises

 Provide badges to all authorized personnel entering the infected premises

 Require all personnel to sign in and out of the premises

 Seal truckloads at the origin and ensure the seals are unbroken at the 

destination

 Provide escorts to ensure the loads are undisturbed during transport and 

watch for leakage

Figure 6. Briefing the Carcass Management Team
Open Burning Module 26 | P a g e

Waste Classification and Characterization

Classification is a determining factor in considering whether a management option is 

appropriate for each type of waste. Because regulations may vary between states, do 

not assume all states’ waste classifications and associated regulations are similar. This 

is particularly relevant if waste generated during a response is transported across state 

lines. Consult a certified waste management professional when classifying waste.

Response personnel should perform the following:

 Identify all waste materials designated for management (in accordance with the 

site-specific carcass management plan, if available). For more information, refer 

to the Emergency Management Tools Module. 

 Mark waste materials if possible and verify with the Disposal Group Supervisor 

that all designated materials are to be disposed of

 Sort materials by type (recyclables, putrescible waste, debris, medical/infectious 

waste such as sharps, and potentially hazardous waste)

 Stage the various waste materials in suitable areas and containerize putrescible 

or wet materials to avoid leaching to the environment. Waste materials may 

require secondary containment to collect runoff and leachate, and coverings such 

as tarps or shelter coverings.

 Estimate the quantities of each waste type and record the information 

 Characterize each waste type in accordance with all applicable local, state, and 

federal regulations

 Improper waste storage and management can result in civil and criminal

penalties (fines or imprisonment)

 Document the characteristics of each waste type and label all waste types

in accordance with applicable regulatory requirements
Open Burning Module 27 | P a g e

Material, Supplies, and Equipment

The Disposal Group must identify all necessary materials, supplies, and equipment to 

carry out the chosen site-specific carcass management method(s). 

The list is provided as an example of the types of materials, supplies, and equipment 

which might be needed for open burning: 

 Personal protective equipment appropriate for heat, flames and sparks

 Personnel, supply, and equipment decontamination equipment

 Secure transport equipment (driven by trained drivers) for carcass loading and 

unloading

 Vehicle cleaning and disinfection equipment

Figure 7. Example Supplies Needed for Cleaning and Disinfection
Open Burning Module 28 | P a g e

Material, Supplies, and Equipment (cont.)

 Vehicle liners, such as plastic sheeting or specialized bags

 Heavy equipment to move the carcasses from staging area to the pyre and to 

place into the pyre

 Absorbent material to prevent leakage

 Regulatory authority approved containers, including sharps containers 

 Bio hazardous waste bags and containers, if applicable Note: use biohazard 

bags only for identified biohazard waste. Putting non-biohazard waste into 

biohazard bags results in excess expenses for waste management. 

Biohazard Waste

Includes plastic ware such as pipettes or pipette tips, culture plates, specimen vials, etc. 

that are contaminated with biological specimens, bacterial and cell culture material, or 

nucleic acids. It also includes towels and bench paper that are biologically contaminated 

(i.e., used where samples or cultures are opened and manipulated). It may also include 

culture or sample containers (e.g. plastic tubes of blood) that are contaminated with 

biological materials. The categories are based on the UN assigned by the United 

Nations Committee of Experts on the Transport of Dangerous Goods (UNECE).

Additional equipment and spare parts must be available for:

 Excavation of trenches or pits if burying ash onsite

 Ash disposal

 Firefighting

 Emergency communication systems

Material requirements for open burning may include:

 Dry straw or hay

 Untreated timbers

 Kindling wood – dry with a low moisture content, and not from green vegetation

 Coal

 Diesel fuel 

Ensure a sustained supply of fuel source, an adequately sized area for unloading and 

storage and for continued combustion. 
Open Burning Module 29 | P a g e

Temporary Carcass Storage

When the Euthanasia Group generates mortalities at a faster rate than the Disposal 

Group can process them, some means of temporary carcass storage must be provided. 

It is important to identify where carcasses can be collected and stored until carcass 

management can commence. Guidance related to storage and collection of solid waste 

which may have some relevance to carcass collection and staging, refer to 40 CFR 

243.200-1(a).

Considerations for temporary storage include:

 Can the storage area be secured to prevent unauthorized access, scavengers, 

odors, rapid decomposition, and potential disease spread to susceptible species?

 Will the carcasses be stored using refrigeration or some other stabilization 

method such as grinding and preserving them in containers? 

 If so, are the equipment, supplies and materials available?

 Can the equipment be cleaned and disinfected?

 Will the storage capacity be sufficient to accommodate the difference between 

the maximum expected euthanasia rate and the maximum carcass management

rate? 

 If not, avoid euthanizing animals at a rate that exceeds carcass 

management and storage capacity

 When maximum carcass management and storage capacities are 

reached, curtail euthanasia until adequate capacity is available

 Consult with Incident Coordination Group leadership for strategies to 

minimize the number of animals to be euthanized and managed
Open Burning Module 30 | P a g e

Secure Transportation

Transport vehicles will be needed to move carcasses and other materials from 

barns/pens to the burn site. If the material must travel on public roads, it should be 

transported in closed, leak-resistant and/or lined trucks or dumpsters. Secondary 

containment may be needed, depending on the type of material being transported. 

Consult a certified waste management professional when developing this section of the 

carcass management plan. Some transport planning considerations are listed below:

 Are haulers to be used for the response properly equipped to haul carcasses in 

accordance with all applicable laws?

 Are transport vehicles designed to handle the materials to be transported?

 Are the drivers adequately trained in biosecurity? 

 Can two-way communications be maintained with the hauler during transport?

 Do shipments require law enforcement escorts or approved routing to avoid 

sensitive areas?

 Will travel routes from the barns/pens to the burn site avoid uninfected farms, 

road construction, neighborhoods, and densely populated areas?

 Has an alternate travel route been identified?

 What procedures will be followed if the vehicle is damaged during transit?

 How is the waste classified for transport? What packaging standards apply? Are 

all standards consistently met, including labeling, placarding, and manifesting, if 

required?

 How will transport vehicle traffic be minimized into the Control Area?

For more information, refer to the Secure Transport Module.
Open Burning Module 31 | P a g e

Site Suitability 

Members of the carcass management team must contact or visit the premises and/or 

the appropriate state regulatory authorities to ensure open burning is accomplished in 

accordance with all applicable laws and regulations. See the Site Specific Carcass 

Management Plan in the Emergency Management Tools Module. 

During an animal disease outbreak, the carcass management team should consider the 

following: 

Selection of environmentally suitable locations for open-burning of infected livestock 

carcasses is important in the disease management process

 Because of the virulent nature of many pathogens, it is important to locate such 

sites within or in close proximity to the infected premises 

 The site access should be able to handle heavy truck traffic and allow for 

biosecurity around the site’s perimeter

 Will open burning create a hazard due to reduced visibility from smoke?

 Due to the relative putrescibility of the carcasses and associated 

manure/bedding, as well as the quantity and density of smoke that will result from 

open burning, it is critical to choose sites that will not be adversely impacted by 

potential releases of nutrient-laden leachate nor will result in nuisance complaints 

in the event that smoke, odors, flies, or scavengers begin to appear on-site

 Site should not pose a risk of starting a grassland or forest fire
Open Burning Module 32 | P a g e

Operations Lesson Overview

This lesson contains general procedures in preparing for and managing carcasses by 

utilizing open burning. The following topics will be addressed: 

 Open burning preparation

 Health and safety

 Open burning operations

Critical steps used during recent U.S. animal disease outbreaks are also included.

Figure 8. Carcass Management Team Wearing PPE
Open Burning Module 33 | P a g e

Operations Lesson Contents

The material in this lesson is presented in a step-wise manner that provides detailed 

instructions and key steps based on the criteria and measures instituted during recent 

U.S. animal disease outbreak responses.

 Incident Management – Provides general guidelines to the Disposal Group 

personnel when dealing with an animal emergency situation

 Infected Premises Preparation – Lists steps for assessing facility readiness to 

begin operations

 Open Burning Operations – Describes procedures for safe and proper carcass 

management using open burning 
Open Burning Module 34 | P a g e

Incident Management

All Disposal Group personnel should familiarize themselves with the approved sitespecific carcass management plan. The Disposal Group Supervisor should review the 

plan with the Disposal Group and brief them on all relevant aspects of the carcass 

management effort. For further guidance, refer to the FAD PReP APHIS Foreign Animal 

Disease Framework: Roles and Coordination. 

1. The Incident Coordination Group (ICG) / Incident Management Team (IMT) 

should ensure there is a system in place to identify carcass management team 

members with the required expertise.

2. The Disposal Group Supervisor, Disposal Coordinator, or other assigned officials

should verify the credentials, training, and security clearances, and arrange justin-time training for carcass management team members.

3. The Disposal Group Supervisor should prepare briefings and reports for the 

Operations Section Chief.

4. The Safety Officer should brief all responders on safety precautions and will 

provide a briefing on the nature of the disease and other circumstances affecting 

the response.

5. The Safety Officer or Biosecurity Officer should brief all responders on 

biosecurity protocols

6. Plans should be developed to be sure that all onsite carcass management 

related personnel are briefed on safety requirements, site conditions, and tasks.

7. The Public Information personnel should develop material, such as Frequently 

Asked Questions, to address public concerns.
Open Burning Module 35 | P a g e

Infected Premises Preparation

1. Consult with local, county, state, and federal environmental officials to obtain 

specific information for the region or community in order to minimize any negative 

environmental effects associated with the open burning of infected carcasses.

2. Determine all applicable public health or environmental protection laws, including 

fire codes and other regulations.

3. Consider regional climate and seasonal trends (e.g., general direction of 

prevailing winds, precipitation, thermal factors).

4. Verify the availability of adequate carcass storage facilities such as refrigerated 

rooms, transport vehicles, freezers or other means of carcass preservation if 

needed.

5. Identify haulers, if applicable, who:

 Are equipped to haul carcasses in accordance with State and Federal 

laws

 Can provide secure, leak resistant, transport for the infected carcasses 

and contaminated materials

 Possess vehicles in good mechanical condition and capable of carrying 

the load without difficulty

 Have vehicles which can be covered with a tarpaulin if they do not have 

closed tops

 Employ licensed drivers adequately trained (see 49 CFR 172 and 49 CFR 

173 for further guidance)

 Have an emergency plan which addresses spills/excess leakage; vehicle 

break-downs; traffic accidents; adverse weather conditions; terrorist 

attacks
Open Burning Module 36 | P a g e

Infected Premises Preparation (cont.)

6. Calculate the amount of material required to accomplish the open burning. One 

adult bovine carcass is equivalent to five finishing pigs or five adult sheep. 

According to US and Canadian experience, one adult bovine carcass may 

require the following quantities of materials. Note: this list is an example of 

quantities and types of materials that may be required; actual requirements will 

vary based on conditions and available materials at the time and place of the 

incident. 

 3 bales of straw or hay,

 1 cord (128 cubic feet) untreated heavy lumber,

 50 pounds of kindling wood,

 100 pounds of coal pieces that are 6–8 inches in diameter, and

 5 gallon of liquid fuel. Do not use gasoline. The type and amount of fuel 

used for incineration will be influenced by local fuel availability and 

conditions. For effective burning, fuel should be as dry as possible.

7. Obtain equipment such as mechanical chains and lifting equipment. Identify 

personnel properly trained in the use of this equipment. 

8. Ensure fire safety equipment is readily available.

9. Ensure only properly trained and credentialed personnel conduct open burning 

and that local fire authorities are included in decision making.

Estimating Average Bovine - Equivalent Carcasses

 1 adult cow or bull - 1 bovine-equivalent carcass

 5 adult swine - 1 bovine-equivalent carcass

 5 adult sheep - 1 bovine-equivalent carcass
Open Burning Module 37 | P a g e

Open Burning Operations

1. Consult with the appropriate state regulatory agencies for air-quality and solidwaste management requirements on potential sites before initiating carcass 

management operations.

2. Work with the local authorities, including firefighting officials, about the planned 

open burning. Secure ample fire retardant, equipment, personnel, and gear. 

Provide the appropriate cleaning, disinfection, space and personal protective 

gear.

3. Ensure availability of adequately prepared work area (e.g., paved or gravel pad) 

to support operations.

4. Coordinate with the local utility company to provide electricity (for example, drop 

service from power lines for different electrical equipment), and secure batteries 

and generators for remote sites

5. Calculate space requirements. Allow a fire-bed length of at least 3 feet for:

 One adult cattle carcass

 Five swine carcasses 

 Five sheep carcasses

6. Ensure all employees involved in the operation wear PPE in accordance with 

CDC, OSHA, the incident-specific Health and Safety Plan (HASP). APHIS 

employees should refer to the APHIS Emergency Management, Safety and 

Security Division EMSSD website for more information.

7. Prepare the bed:

 Build the fire bed in a manner to minimize the amount of sparks, soot, and 

objectionable odors blowing toward buildings or across public roads

 Stake out and fence the selected burning site for the fire-bed construction

making sure to allow access for equipment needed to maintain the burn

 Allow a fire-bed length of at least 3 feet for each adult cattle carcass, five 

swine carcasses, or five sheep carcasses

 Lay three rectangular rows of straw or hay bales lengthwise along the line 

of the fire bed. Rows should be 12 inches apart and each bale should be 

separated by a 12 inch gap.
Open Burning Module 38 | P a g e

Open Burning Operations (cont.)

 Place loose straw in the spaces between the rows and bales to provide natural 

air flow

 Place large pieces of lumber lengthwise on top of each row. Distribute large and

medium-sized pieces of lumber across the fire bed, leaving 6-12 inches of space 

between them.

 Place small kindling wood on the fire bed and cover loosely with straw

 Spread 6-8 inch-diameter coal evenly at the rate of 500 pounds per square yard; 

use of a liquid fuel such as diesel or furnace oil may cause soil and groundwater 

contamination, so is not recommended unless small amounts are required to 

initiate the pyre. Then, solid fuels should be used to maintain combustion. 

 This process must be approved by appropriate state or local regulatory agency

 Lay the carcasses on the fire bed

 Use mechanical chains and lifting equipment (such as front-end loaders) to 

accomplish all the loading, spreading, and handling of solid fuels and carcasses

 Position carcasses on their backs with their feet in the air and alternately head to 

tail if possible

 Two goats, sheep, or swine carcasses can be placed on top of each bovine 

carcass and burned without additional fuel 

 Place loose straw on top of the carcasses and all spaces in between

 Spray liquid fuel over the fire bed with a pump, or use sprinkling cans or buckets

 Soak rags in kerosene oil or waste oil and place them every 30 feet along the fire 

bed for a better and more harmonized ignition

 Make sure that people and equipment are at least 25 feet from the burning pile

 Have fire-fighting equipment readily available

 Ignite the fire bed; stir the burning pile with front-end loaders. Add more fuel as 

needed.

WARNING

 DO NOT burn carcasses with explosive or highly volatile materials, such 

as gasoline. (Consult fire department or state environmental regulators 

for acceptable accelerants)

 DO NOT burn carcasses with tires, rubber, plastics, or similar materials

 DO NOT allow personnel to approach the carcass-burning site from 

downwind without proper personal protective equipment
Open Burning Module 39 | P a g e

Open Burning Operations (cont.)

8. Upon completion of the open burning operation, thoroughly clean and disinfect all 

contaminated equipment. See the FAD PReP SOP15: Cleaning and Disinfection

and FAD PReP SOPs: Biosecurity.

9. Dispose of ash in accordance with permit requirements after all carcasses have 

been burned completely and the fire has been extinguished. Note: It may be 

several days before the ash is cool enough to be managed without damaging the 

heavy equipment used to move it.

10.If allowed by permit and approved nutrient management plan, apply the ash to 

agricultural lands. Otherwise, dispose in accordance with applicable local, state 

and federal requirements.

11.Restore open-burning site to its original condition
Open Burning Module 40 | P a g e

Summary

Congratulations! You have completed the Open Burning Module. In this module, you 

have learned to:

 Describe open burning as a method for carcass management

 Understand the advantages and disadvantages of open burning 

 Identify personnel health risks associated with open burning 

 Consider environmental risks associated with open burning

 Obtain regulations governing open burning by consulting with state officials

 Identify factors used to evaluate open burning as a carcass management option

 List critical elements when planning open burning

 Recognize key components of open burning operations

Please click here to download the certificate of completion for this module. You can 

enter your name on the certificate and save or print it for your records.